Federal Tax Controversies

At Neschis & Tolitano, we have a diversified and comprehensive federal tax controversy practice that covers a broad spectrum of tax issues. As Chicago federal tax law attorneys, we regularly assist taxpayers at all levels of disputes with the IRS from audit to appeals and/or mediation and through litigation in the United States Tax Court or United States District Court.

Tax Audits, Appeals and Litigation

Our representation at the audit level involves developing strategies for all issues involved in the audit and responding to all of the IRS's information and document requests and to all of the IRS's proposed tax adjustments to a taxpayer's tax return. If the taxpayer and the IRS do not agree on one or more items in the audit, the taxpayer may file an appeal with the IRS Office of Appeals. We are skilled negotiators and have significant experience representing individuals and businesses at the appeals stage. We also have significant experience with the numerous alternative dispute resolution options available to taxpayers during the audit and appeals processes. Additionally, we also represent taxpayers who dispute a tax assessment in court. A litigation case can typically be initiated by a taxpayer who does not agree with the audit results or appeals decision and after receiving a notice of deficiency or by filing a claim for refund with the IRS.

We also have extensive experience assisting taxpayers become compliant with U.S. tax laws related to undisclosed foreign accounts and assets. These cases typically involve taxpayers who have failed to report their foreign income on their originally filed income tax returns and have failed to file an annual Report of Foreign Bank and Financial Accounts (FBAR) form. We have also assisted in tax audits and criminal investigations related to these accounts and assets.

Tax Collection Matters

As Chicago federal tax law attorneys, we regularly represent taxpayers with outstanding tax liabilities before the IRS's collection division. Our tax collection cases involve a broad range of tax collection assistance and include the following:

  • Installment agreements
  • Offers of compromise
  • Abatement of penalties
  • Release, withdrawal, discharge and subordination of federal tax liens
  • Release and withdrawals of levies, including wage garnishments and bank levies
  • Innocent spouse relief
  • Currently uncollectible status
  • Collection due process notices
  • Trust fund liability or civil penalty assessments
Client Reviews
Sam represented our business and us personally in a contract action at a very volatile time in our lives. Not only was he knowledgeable, but his compassion and concern for us not only as clients, but as people, went above and beyond any expectations we might have had. It is very rare to find a strong legal advocate who can maintain poise, calmness, and confidence during hostile negotiations. We were listened to, consulted, and kept informed of all aspects of the litigation, and his concern for us financially was refreshing and much appreciated. We wholeheartedly give Sam our highest recommendation. Patricia
Sam and his team have worked with me and my team for years, and we could not be more satisfied. His level of comprehension of what is really being said to his attention to detail regarding the minutia of each statement has been of such value to me not only in peace of mind, but the very concrete financial results. When you have to engage an attorney for anything, you want the best person for the job, and the best person for you, Sam is absolutely both to me and my team. I have recommended both family and friends to this firm with the utmost confidence. Sam continues to serve what started as a single issue to become the go-to for all of my ventures. He's very unassuming, and quietly brilliant, and that is what we look for, delivery without the unnecessary and silly pinstripes and fake tans. I have entrusted Sam with my business for years, and will not go outside this firm. Ever. I cannot sing his praises enough. He's helped me get the best result out of a horrible situation, and is now spearheading all my companies to new heights. This firm represents the best of the legal practice, acting as council, friend and strategist. Justin P.
Sam Neschis has represented my companies for approx 7-8 years. I work in the financial / mortgage / real estate industry and overall don't trust anyone. I trust Sam, and I know and feel he is always looking out for my best welfare. Sam can service many areas in my line of work, but if Sam isn't the best suited attorney in the legal area I need help in, he always goes out to help find the proper attorney to assist me and my needs. In other words he just insn't going to bill to bill. He tells you if he can handle the file, but if he can't - Sam cares enough to send you in the proper direction. After I met Sam in person, it really sealed the deal for me. He is calm cool and collective - I like Sam as a person and as an attorney.. Thank You Sam!!!! I would recommend Sam Neschis to anyone and everyone!!!! Anonymous